Passenger Loses Both Legs After Reclining Seat Lets Him Slide Under Seatbelt in Toyota Head-On Crash

On the afternoon of June 8, 1997, Prashant Kumar, then 25, was riding as a front-seat passenger in a 1996 Toyota Tercel on New Jersey State Highway 40. His seat was reclined. When a Cadillac driven by Alfred C. Shumar crossed the center line and struck the Tercel head-on, Kumar was flung forward with enough force to slide beneath his seatbelt. The collision left his legs destroyed. Both were amputated above the knee.

Shumar and two passengers in his car died at the scene. Kumar survived, but with injuries the legal team documented as catastrophic: bilateral above-knee amputations, lung damage, broken bones, and a projected life expectancy shortened to age 50.

The product-liability claim against Toyota turned on a single design and warning question: the Tercel's passenger seat reclined without any in-vehicle warning that doing so would undermine seatbelt protection, allowing a passenger to submarine beneath the lap belt in a frontal crash. The owner's manual mentioned the hazard, but the legal team argued -- successfully -- that a warning buried in a manual that passengers have no reason to consult before riding fails the standard Toyota owed its customers.

Robert Langdon of Langdon and Emison, serving as a lead member of the legal team alongside co-counsel Paul Bekman, Kent Emison, Michael Morgenstern, and Stuart Salsbury, helped develop the trial strategy across what colleagues described as eighteen-hour days working from Bekman's Baltimore offices. Expert testimony from Dr. Joseph Burton addressed the biomechanics of how seat angle directly affects seatbelt geometry during a frontal impact.

In May 2000, the Baltimore City Circuit Court jury returned a verdict of $59.7 million. The trial judge later reduced the award to $16 million. Toyota appealed. In August 2003, the Court of Special Appeals of Maryland upheld the $16 million judgment, with Judge James P. Salmon writing that the evidence about the hazards of fully reclined seats was 'crystal clear' and that Toyota should have placed an explicit warning on the vehicle itself. Under New Jersey law, which applied because the collision occurred in that state, Toyota bore 30 percent of liability.